LBS Slavery and human trafficking statement

Last updated September 2018

The Modern Slavery Act 2015 (“act”) was introduced to help eradicate slavery, forced labour and human trafficking in the operations and supply chains of companies. This statement is made pursuant to Section 54, Part 6 of the act and includes information about LBS, its own operations and supply chains, and how we are approaching the eradication of slavery and human trafficking within our business. 

Our commitment

LBS is committed to preventing and mitigating exploitation, bribery and corruption.  We will not accept modern slavery, forced labour and human trafficking anywhere within our operations or supply chain.   

The Modern Slavery Act 2015

LBS is subject to legislation in the UK aimed at the prevention of modern slavery and human trafficking. The Modern Slavery Act 2015 imposes on LBS the obligation to take steps to prevent slavery and human trafficking occurring in its business and supply chains. 

LBS are fully committed to preventing acts of modern slavery and human trafficking from occurring within both their business and supply chains and requires the same standards from their suppliers. 

This document sets out the standards that LBS expects from its suppliers to deliver this commitment. LBS monitors compliance by suitable levels of due diligence according to the level of risk which LBS assesses of the potential for human trafficking and/or modern slavery. 

Any instances of non-compliance of which LBS is made aware will be assessed on a case-by-case basis. Remedial action will be taken and tailored to suit the circumstances. LBS will only trade with those who fully comply with this statement or those who are taking steps towards full compliance. If LBS is not satisfied with the steps being taken towards full compliance, it will temporarily suspend its business with that supplier (to the extent permitted under contract or by law). The ultimate sanction for the continual failure to comply will be for LBS to cease to trade with that supplier ( to the extent as permitted under contract or by law).

We expect our suppliers to implement their own diligence procedures for their own suppliers, sub-contractors and other participants in their supply chains to mitigate the risk of any slavery or human trafficking occurring. Suppliers should notify us in writing immediately upon discovery of any breaches or potential breaches of the Modern Slavery Act or any actual or suspected slavery or human trafficking in their supply chain. We aim to co-operate with our suppliers to mitigate the risks of such incidents. 

Any suppliers that are obligated under the Modern Slavery Act to provide a slavery and human trafficking statement for the financial year should produce a statement which is fully compliant with both the act and our own slavery and human trafficking statement. 

LBS and all suppliers are required to provide affirmation to the standards listed below:

The Standards

1. Wages and Benefits, Working hours (Fair treatment of Employees)
   LBS and all suppliers will provide compensation and benefits which are in accordance with minimum wages, overtime hours and statutory benefits in conformity with applicable laws of the jurisdiction in which the supplier operates or industry standards or relevant International labour must be granted at least one day off following six (6) consecutive working days and employees must be granted appropriate holiday arrangements according to local laws. Suppliers should provide their employees with a way to express grievances without fear of reprisal. 
   
   
2. Child Labour, Minimum Age
   LBS and all suppliers will not employ child labour in contravention of local laws or ILO Convention 182. This includes the sale/trafficking of children, debt bondage and forced labour. Children must not undertake work which is likely to harm their health, safety or morals. LBS and all suppliers must ensure that their employees meet the minimum age for admission to employment based on local laws or ILO Convention 138.
   
   
3. Forced Labour
   LBS and all suppliers will not use forced labour in any form, including human trafficking, or any physically abusive disciplinary procedures. Employees must be free to leave employment of suppliers with reasonable notice. LBS and all suppliers must ensure that employees are not being mentally or physical coerced to provide their labour. 
   
   
4. Freedom of Association
   LBS and all suppliers must permit workers to associate freely, join trade unions and join workers’ councils in accordance with ILO Convention 87. These organisations should have the right to draw up their own constitutions and rules, elect their own representatives and organise their own activities. 
   
   
5. Health and Safety 
   LBS and all suppliers will conform to all health and safety legislation applicable in the jurisdiction in which supplier operates.
   
   
6. Harassment and Discrimination
   LBS and all suppliers will not harass or discriminate against employees on the basis of gender, race, colour, religion, age, national origin, sex, gender identity or disability. Suppliers should take steps to ensure that their work places are free from discrimination or any physical or verbal harassment. 
   
   
7. Right to work
   LBS and all suppliers will conduct the appropriate checks to ensure that all employees have the right to work in their relevant jurisdiction.
   
   
8. Incident Management
   LBS and all suppliers should have sufficient protocols in place to manage a breach or potential breach of the Modern Slavery Act.